Data, Evidence & Insights

Conflict Minerals Policy

OVERVIEW

In 2012, the Securities
and Exchange Commission adopted rules implementing the conflict minerals
provisions of the Dodd-Frank Act (the “Conflict Minerals Rules”). This requires public companies to annually
disclose information about whether the products they manufacture or contract to
manufacture, for which 3TG Minerals are necessary to the functionality or
production of those products, contain 3TG Minerals that originated in any of
the Covered Countries. If so,
information about the source and chain of custody of those 3TG Minerals must
also be disclosed.

SCOPE

This Policy
applies to Studiomaca’s employees who manage relationships with suppliers of
products to Studiomaca, its subsidiaries, and its affiliates.

POLICY DETAILS

Our supply chain
is highly complex, and our manufacturing process is significantly removed from
the mining, smelting and refining of 3TG Minerals. As a result, we expect that
all of our suppliers will partner with us to provide appropriate information
and conduct necessary due diligence in order to facilitate our compliance with
the Conflict Minerals Rules. We are
committed to working with our suppliers to educate them about these issues and
the steps that they can take to increase the transparency of the supply chain.

Studiomaca suppliers
are expected, upon request, to:

Identify the steps in the supply
chain through which 3TG Minerals are introduced, and undertake all due
diligence efforts necessary to identify the smelter, refiner and/or mine
from which 3TG Minerals originate. This may include requiring direct or
indirect suppliers to our suppliers to cooperate in diligence efforts and
to provide any information necessary to facilitate our compliance efforts
with respect to the Conflict Minerals Rules;

Supply us with timely and accurate
information regarding the source of 3TG Minerals in our supply chain and
the steps that have been undertaken to determine whether such products and
materials are DRC Conflict Free, including whether the source has been
verified by a recognized, independent third party; and

Advise us promptly of any
determination that any products or materials in the supply chain are not
DRC Conflict Free.

We evaluate our
relationship with our suppliers on an ongoing basis. Although the existence of the Conflict Minerals
Rules is no guarantee that our suppliers will be in compliance or cooperate
with our requests for additional information, the disclosure requirement is
mandatory. If a supplier has failed to
comply with this Policy, or if we determine that a supplier’s efforts are
deficient, we will take appropriate action, which could result in terminating
our relationship with the supplier and securing a replacement supplier who will
comply with this Policy.

Studiomaca employees
are always obligated to report instances of non-compliance with our
policies. To report potential violations
of this Policy, employees should:

Contact their Business Unit
Compliance Officer or Business Unit Lawyer;

Call Studiomaca’s Integrity Line at
1-877-625-4625. Local toll-free
numbers for locations outside the U.S. are listed at
integrity.studiomaca.info.

Studiomaca prohibits
retaliation against those who, in good faith, raise concerns or ask questions
regarding matters of ethics or legal compliance or participate in an
investigation.

Nothing in this
Policy is intended to modify or otherwise limit our contractual or legal
rights.

POLICY DEFINITIONS

“3TG
Minerals” means columbite-tantalite
(coltan), cassiterite, and wolframite (including their derivatives, tantalum,
tin and tungsten), gold, and any other minerals that the U.S. Secretary of
State may designate in the future.

“Covered Countries” means the Democratic
Republic of the Congo, the Republic of the Congo, the Central African Republic,
South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.

“DRC Conflict Free” means that the
product does not contain 3TG Minerals that directly or indirectly financed or
benefitted armed groups in the Covered Countries.